https://www.taxtmi.com/highlights?id=94813 ITAT dismissed Revenue's appeals, upholding taxation of the assessee's receipts under Section 44BB rather than as FTS under Section 9(1)(vii) r.w.s. 44DA, following judicial consistency with earlier years in the assessee's own case. On offshore sale of equipment, ITAT accepted the assessee's 2% profit attribution for Indian operations, relying on prior coordinate bench findings that the assessee's selected comparables satisfied FAR analysis and yielded a weighted average margin of 1.69%. Consequently, no further profit attribution was warranted and AO was directed to accept the 2% margin. en-us Sat, 06 Dec 2025 08:46:10 +0530 Sat, 06 Dec 2025 08:46:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94813 ITAT dismissed Revenue's appeals, upholding taxation of the assessee's receipts under Section 44BB rather than as FTS under Section 9(1)(vii) r.w.s. 44DA, following judicial consistency with earlier years in the assessee's own case. On offshore sale of equipment, ITAT accepted the assessee's 2% profit attribution for Indian operations, relying on prior coordinate bench findings that the assessee's selected comparables satisfied FAR analysis and yielded a weighted average margin of 1.69%. Consequently, no further profit attribution was warranted and AO was directed to accept the 2% margin. Highlights Income Tax Sat, 06 Dec 2025 08:46:10 +0530 https://www.taxtmi.com/highlights?id=94813